Subject: Comment Letter for File Numbers S7-30-22 and S7-32-22 Regulations NMS and Best Execution
From: Ed Clark
Affiliation:

Mar. 28, 2023

 


A successful voyage requires three things. First, the ships must stay
out of each other's way, and they must not collide. Second, the
individual ships must be seaworthy, everything working in proper
order. Third, the fleet of ships must be on its proper course. If they
mean to go to New York, but end up in Calcutta, something has gone
terribly wrong.

With PFOF, none of these are true.  My order gets hijacked by pirates.
My broker is in cahoots with the pirates.  And I end up in the Black
Sea when I was just trying to go home.

We're always thinking about the first thing and forgetting the other
two.  When someone says about something he wants to do, 'It can't be
bad because it doesn't do anyone else any harm,' he is thinking of
only the first thing. He is thinking it does not matter if the ship is
seaworthy provided that he does not run into the next ship...If our
thinking stops there, we might just as well not have thought at all.

If we want the market to be successful and truly flourish, we need to
do more than just avoid harming others.  We need to cultivate trust,
courage, and humility.  Eliminate greed, cowardice, egotistic pride.